The Russian Federal Tax Service (FTS) recently published Guidance Letter ED-4-13/20767, which covers a number issues concerning the determination of related parties, control of foreign entities, and place of effective management.
Determination of Related Parties for Transfer Pricing Purposes
According to the guidance, in determining whether parties are related for transfer pricing purposes the FTS will evaluate the level of influence one party may have on the other through:
- A participatio…